Justia Juvenile Law Opinion Summaries

M.Y.G. was 15 years old when he stole two cars. The State charged him with two counts of theft of a motor vehicle. M.Y.G. moved for and was granted a deferred disposition, but he objected to providing a DNA sample. The trial court ordered M.Y.G. to submit a DNA sample but stayed collection pending appeal. The Court of Appeals affirmed the trial court, upholding the DNA collection. I.A.S. was 17 years old and under the influence of alcohol when he stole a truck, crashed it into a tree, and ran from the scene. The State charged him with one count of second degree burglary, theft of a motor vehicle, second degree theft, driving under the influence, and failure to remain at the scene of an accident. I.A.S. moved for and was granted a deferred disposition. He too objected to providing a DNA sample, but the court ordered him to submit one, staying collection pending his appeal. The Court of Appeal again affirmed the trial court, requiring I.A.S. to give a DNA sample. I.A.S. and M.Y.G. appealed, presenting the question of whether a juvenile was “convicted” when they enter into a deferred disposition. The Washington Supreme Court held that a juvenile is “convicted” when they enter into a deferred disposition. However, the Court held that the juvenile offenses committed by the petitioners in this case did not trigger the DNA collection statute. Therefore, the Supreme Court affirmed the Court of Appeals in part and reversed in part. The orders requiring a DNA sample from M.Y.G. and I.A.S were vacated. View "Washington v. M.Y.G." on Justia Law

The Supreme Court held that the general division of a common pleas court does not have jurisdiction over an offender who was arrested at the age of twenty for felonious acts he allegedly committed as a juvenile.Appellant was arrested at the age of twenty for acts he allegedly committed when he was seventeen years old, acts that would have been felonious had they been committed by an adult. Appellant was first indicted in the general division of the court of common pleas. The State recognized that the general division did not have jurisdiction over Appellant under Ohio Rev. Code 2152.02(C)(3) and 2151.23(I) and moved to dismiss the indictment. The indictment was dismissed, but because Appellant was twenty-two years old at that point, the State reindicted him in the general division the next day. The court of appeals affirmed. The Supreme Court reversed, holding that the jurisdiction of the general division of the court of common pleas is not invoked when a person is arrested at the age of twenty for felonious acts that he allegedly committed as a juvenile. View "State v. Hudson" on Justia Law

The issue presented by this appeal was whether youthful offenders who are statutorily ineligible for early parole consideration were nevertheless entitled to a "Franklin" proceeding to preserve evidence for their eventual parole hearing. During his early 20’s, appellant was involved in three separate criminal incidents. s a result of those incidents, appellant was convicted of kidnapping for robbery and multiple counts of robbery, burglary, false imprisonment and illegal gun possession. He was also found to have personally used a firearm during the offenses and suffered a prior strike conviction. The trial court sentenced him to 59 years to life in prison under the “Three Strikes” law. In 2020, appellant requested a Franklin proceeding to present mitigation evidence in anticipation of his youth offender parole hearing (YOPH). However, the trial court correctly determined appellant was not eligible for a YOPH because he was sentenced under the Three Strikes law. Therefore, it denied his request for a Franklin proceeding. Appellant admitted he was statutorily ineligible for a YOPH because he was sentenced under the Three Strikes law. However, he contended he is entitled to a YOPH – and a concomitant Franklin proceeding – as a matter of equal protection. Although the Court of Appeal rejected appellant’s equal protection argument, both parties concluded he was entitled to a Franklin proceeding under the standard rules applicable to all parole hearings. The trial court's judgment was reversed and the case remanded for such a proceeding. View "California v. Delgado" on Justia Law

In 2012, Birdsall (age 16) and Nicosia murdered Latiolais in her home and stole a car, guns, jewelry, and marijuana. Birdsall had a distant family relationship with the victim and had done work at her home. Birdsall and Nicosia hid outside the house for several hours; when Latiolais did not leave, they decided to kill her and proceed with the burglary. They later returned and set the house on fire. Police arrested and interrogated Birdsall, who made inculpatory statements. Video recordings of the interrogation were played for the jury at Birdsall’s trial. Birdsall presented a mental state defense but was convicted of first-degree murder and arson. The jury found true the alleged special circumstances. The court sentenced Birdsall to life without the possibility of parole for the murder conviction, plus a consecutive five-year term for arson.After the retroactive application of Proposition 57, which requires that a transfer hearing be held in juvenile court before the initiation of adult criminal court proceedings against a minor, the case was remanded to juvenile court, which conducted a transfer hearing and found Birdsall not suitable for juvenile court adjudication and reinstated the original judgment. The court of appeal affirmed, rejecting Birdsall’s argument that the court erred by failing to suppress his inculpatory statements, which he claims were obtained in violation of Miranda and were involuntary, and challenges to his sentence and to one of the jury instructions. View "Peope v. Birdsall" on Justia Law

By passing Proposition 83 (Jessica's Law), voters intended to continue to classify the crime of possession of child pornography as a "wobbler" so that juvenile courts could continue to declare it as either a felony or a misdemeanor.In this case, H.N., a minor, appeals an order of the juvenile court sustaining a Welfare and Institutions Code section 602 petition with a finding that he possessed child pornography. The Court of Appeal concluded that the juvenile court erred by not making an express finding per Welfare and Institutions Code section 702 whether the Penal Code section 311.11, subdivision (a) offense was a felony or a misdemeanor. The court struck the maximum turn of confinement finding H.N. was placed on home probation and remanded to the juvenile court to make a finding whether the offense is a felony or a misdemeanor. The court otherwise affirmed. View "In re H.N." on Justia Law

The Ninth Circuit affirmed the district court's denial of a motion to dismiss a Second Superseding Indictment (SSI) charging defendant with racketeering conspiracy. After determining that it had jurisdiction under the collateral order doctrine to hear this interlocutory appeal, the panel held that the Juvenile Delinquency Act (JDA) does not preclude the government from prosecuting a person as an adult for a continuing conspiracy that includes both pre- and post-majority conduct after the court dismisses a JDA information charging that person with conspiracy based solely on pre-majority conduct.In this case, because defendant's participation in the conspiracy allegedly continued beyond his eighteenth birthday, it was no longer an act of juvenile delinquency under the JDA. Rather, the panel concluded that the conduct became a continuing adult RICO conspiracy offense which began when he was a juvenile but continued when he allegedly engaged in additional acts in furtherance of the ongoing conspiracy after reaching the age of majority. View "United States v. Mendez" on Justia Law

In these three consolidated appeals the Supreme Court held that the State has discretion to charge juveniles under the provisions of either S.D. Codified laws 32-23-1 or S.D. Codified Laws 32.23-21.Defendants, all minors under the age of eighteen, were charged as adults in separate cases for driving a vehicle with a blood alcohol content (BAC) of more than .08, in violation of section 32-23-1(1). Each defendant filed a motion to dismiss, claiming that their status as juveniles stripped the magistrate courts presiding over their cases of jurisdiction. The magistrate courts dismissed the motions, and the circuit courts affirmed. The Supreme Court affirmed, holding that Defendants failed to support their argument that the language of the relevant statutes prevents the State from charging them in magistrate court with violations of section 32-23-1. View "State v. Bettelyoun" on Justia Law

Defendant was convicted of special-circumstance murder and sentenced to life without parole for crimes committed when she was 16 years old. The Court of Appeal affirmed defendant's conviction and remanded for resentencing in light of Penal Code section 190.5, subdivision (b). On remand, the trial court mischaracterized the court's mandate as simply directing a clarification of its prior sentencing decision.The Court of Appeal concluded that defendant is entitled to a sentencing decision made in the exercise of informed discretion by the sentencing court, and the court cannot conclude beyond a reasonable doubt that the outcome would not be different if she were present at the hearing and she and her counsel had a fair opportunity to provide information concerning the youth-related mitigating factors identified in Miller v. Alabama (2012) 567 U.S. 460, and People v. Gutierrez (2014) 58 Cal.4th 1354, 1388-1389. However, the court concluded that a different result is not possible before the judge who has previously heard the matter. Accordingly, the court reversed the judgment and again remanded for resentencing with all further proceedings to be heard before a different trial judge. View "People v. Guerrero" on Justia Law

The Supreme Court reversed the judgment of the juvenile court denying RH's petition for expungement of his record pursuant to Wyo. Stat. Ann. 14-6-241, holding that the district court erred in interpreting sections 14-6-241(d) and (e).When RH was sixteen years old the State filed a delinquency petition against him. RH agreed to a deferred prosecution and successfully completed the terms of his deferral. Thereafter, the juvenile court dismissed the delinquency petition. RH later petitioned for expungement of his record. The juvenile court denied the petition, concluding that RH was statutorily ineligible to have the record expunged because the petition charged him with a violent felony. The Supreme Court reversed, holding that section 14-6-241 allows expungement of a juvenile record where a delinquency petition was dismissed but the delinquent act charged was a violent felony. View "RH v. State" on Justia Law

Kevonta Daniels was convicted by jury of felony murder in connection with the shooting death of Kenneth Moore; the aggravated assaults of Jai Williams, Jamal Williams, and James Williams; the theft of vehicles belonging to Jamal Williams, Marcus Jones, and Alvin Walker; and other offenses. Following the denial of his motion for new trial, Daniels argued on appeal that the trial court erred by admitting statements he made to the police into evidence at trial. Daniels, who was 14 years old at the time of the crimes and when he was interviewed by the police, specifically argued the State failed to prove that he knowingly and voluntarily waived his constitutional rights before speaking with the police and that his statements should also have been excluded because the police failed to comply with provisions of the Juvenile Code relating to custody of juvenile arrestees. Finding no reversible error, the Georgia Supreme Court affirmed. View "Daniels v. Georgia" on Justia Law